Lead Paint

On July 15, 2011, the Environmental Protection Agency (“EPA”) rejected its own proposed revisions to the Lead Renovation, Repair and Painting Rule (the “RRP Rule”), which went into effect in April 2010. The RRP Rule established accreditation, training, certification, and recordkeeping requirements as well as work practice standards for persons performing renovations for compensation in most pre-1978 housing and child-occupied community facilities, such as day care centers and kindergarten classrooms. In May 2010, as part of a settlement of litigation over post-renovation cleaning requirements in the RRP Rule, EPA proposed revising the RRP Rule to add certain requirements in order to demonstrate that minimal dust-lead levels remained in the work area after the completion of renovations. These proposed requirements were similar to those requirements applicable after lead abatement work has been conducted.